Beneficial ownership transparency: at the heart of Armenia’s anti-corruption agenda

Louise Russell-Prywata · Dec 2019

This month, OpenOwnership has been in Yerevan providing technical assistance to support the development of Armenia’s beneficial ownership register, and conducting the next phase of our scoping review of opportunities to advance beneficial ownership transparency.

Armenia is leading the way on beneficial ownership transparency in the Caucasus region, having already commenced development of a pilot register for extractives that will be expanded to include all sectors by the end of 2020. In keeping with this progress, Armenia is set to become one of the first countries to join the Beneficial Ownership Leadership Group, a newly formed coalition of governments that is committed to advancing progress towards open beneficial ownership registers and sharing good practice.

During our technical assistance and scoping mission, Kadie Armstrong, one of our technical experts, and I met with government officials responsible for developing the legal framework for beneficial ownership transparency. This will initially mandate a sector-specific public beneficial ownership register covering extractives companies, and subsequently a public beneficial ownership register covering privately held Armenian companies across all sectors. We discussed the legislative options and current drafts in detail, working through areas covered by our Policy Reviewer tool.

We also met with management and staff at Armenia’s state registry and with the technical lead maintaining the current company register to understand the data flow from submission of company information through to publication on Armenia’s e-register. In addition to discussing the details of the current systems and data model and the requirements of the Beneficial Ownership Data Standard, we piloted a new methodology that we are developing for reviewing the technical systems and digital context for beneficial ownership reform. We will refine this tool in the coming weeks and publish it so that others supporting the technical aspects of beneficial ownership transparency can both use it and help improve it.

Armenia’s beneficial ownership implementation is taking place within an extensive digital infrastructure, with multiple e-government services currently connected through a cloud-based hub. Information-sharing across agencies is automated and commonplace. We were excited to learn about the set of minimum interoperability requirements that exist for all government digital systems as well as the good practice currently in operation within the company register, such as use of permanent and unique identifiers for all companies. This offers a solid foundation for publishing beneficial ownership data.

Finally, we met with civil society and mining company representatives from Armenia’s EITI multi-stakeholder group, to discuss their ambitions and concerns for the extractives sector beneficial ownership register. This is intended to serve as a pilot for Armenia’s cross-sector register, and so provides an interesting opportunity to test both the legislative and technical approaches adopted and to refine and improve them on a comparatively short timescale. One of the challenges of our technical assistance over the coming weeks therefore will be to support the government in drafting a legal framework mandating disclosures that are as detailed as possible. This new framework has to exist within current legislation on data protection and will enable companies to clearly understand what information they need to disclose.

We’ll be publishing our full scoping review and recommendations by April 2020, relating to the extractives pilot and the subsequent establishment of Armenia’s open beneficial ownership register for companies in all sectors. But pending the publication of our full scoping review, our preliminary assessment is that Armenia is in a strong position to disclose data. Moving forward, we’ll be assisting Armenia in refining its draft regulations for beneficial ownership data collection in the extractives sector and supporting the development of software and systems to collect, store and publish beneficial ownership data.

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